Case Digest (G.R. No. 132980) Core Legal Reasoning Model
Core Legal Reasoning Model
Facts:
On February 5, 1972, respondent Rene V. Ongpin married Alma D. Mantaring in Quezon City. Mantaring later obtained a divorce decree from the District Court of Clark County, Nevada, which Ongpin believed valid, leading him to wed petitioner Mary Elizabeth Mercado in Princeton, New Jersey on April 21, 1989. The spouses separated on March 16, 2000. In November 2003, Ongpin secured a judicial declaration of nullity of his first marriage. On January 8, 2006, he filed a petition for declaration of nullity of his marriage to Mercado before the Regional Trial Court (RTC) of Bacoor, Cavite (Branch 89, Civil Case No. BCV-2006-68) under Article 35(4) of the Family Code, asserting bigamy. Mercado countered that their marriage was valid under Article 26 of the Family Code and argued that Ongpin’s petition aimed to evade liability in her pending separation‐of‐property suit filed in 2002. She sought moral and exemplary damages and attorney’s fees. On November 12, 2009, the RTC declared the marr Case Digest (G.R. No. 132980) Expanded Legal Reasoning Model
Expanded Legal Reasoning Model
Facts:
- Parties and Marriages
- Rene V. Ongpin (Ongpin) married Alma D. Mantaring (Mantaring) in Quezon City on February 5, 1972. Mantaring obtained a divorce decree in Nevada.
- Believing himself divorced, Ongpin married Mary Elizabeth Mercado (Mercado) in New Jersey on April 21, 1989; they separated March 16, 2000.
- Procedural History
- Ongpin secured a Philippine declaration of nullity of his first marriage on November 25, 2003.
- On January 8, 2006, he petitioned the Bacoor RTC to declare his marriage to Mercado void under Family Code Art. 35(4) (bigamy). Mercado countered that their marriage was valid (Art. 26) and alleged the petition was a scheme to evade a pending property separation suit; she claimed moral and exemplary damages and attorney’s fees.
- November 12, 2009 RTC Decision: declared marriage void; awarded Mercado ₱250,000 moral damages, ₱100,000 exemplary damages, and ₱150,000 attorney’s fees.
- Ongpin appealed only the damages awards. February 21, 2013 Court of Appeals Decision: deleted awards of moral and exemplary damages and attorney’s fees. May 22, 2013 CA Resolution: denied Mercado’s motion for reconsideration.
- Mercado filed a Rule 45 Petition for Review in the Supreme Court, contending bad faith and malice were proved; Ongpin filed comments; memoranda were submitted.
Issues:
- Whether factual questions (bad faith; entitlement to damages) are reviewable under Rule 45.
- Whether Mercado is entitled to moral damages, exemplary damages, and attorney’s fees.
Ruling:
- (Subscriber-Only)
Ratio:
- (Subscriber-Only)
Doctrine:
- (Subscriber-Only)